ML17285B188: Difference between revisions

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See also: [[followed by::IR 05000397/1990001]]


=Text=
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{{#Wiki_filter:WASHINGTON
{{#Wiki_filter:WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 988<3000 George Wash/ngton Way~Rfrhland, Washlngton 893$2 April 11, 1990 602-90"074 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C, 20555 Gentlemen:
PUBLIC POWER SUPPLY SYSTEM P.O.Box 988<3000 George Wash/ngton
 
Way~Rfrhland, Washlngton
==Subject:==
893$2 April 11, 1990 602-90"074
NUCLEAR PLANT NO.2, OPERATING LICEHSE NO.NPF-21 HRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
Docket No.50-397 U.S.Nuclear Regulatory
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
Commission
V ery truly yours, G.D.Bouchey, Director Licensing 8 Assur ance JDA/bI<Attachments cc: JB Hartin-NRC RV NS Reynolds-BCPIER RB Samworth-NRC DL Williams-BPA/399 ,NRC Site Inspector-901A APPENDIX A During an NRC inspection conducted on January 29,-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.
Attn: Document Control Desk Hail Station Pl-137 Washington, D.C, 20555 Gentlemen:
In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A.10 CFR 20.201,"Surveys.," states in part: (a)'As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...Mhen appropriate, such evaluation includes.;.measurements of levels of radiation or concentrations of radioactive material present.(.b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.
Subject: NUCLEAR PLANT NO.2, OPERATING LICEHSE NO.NPF-21 HRC INSPECTION
Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.
REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington
This is a Severity Level IV violation (Supplement IV), Val i f Viola n The Supply System acknowledges the validity of this violation.
Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990.Our reply, pursuant to the provisions
The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential For the spread of contamination.
of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
Furthermore, radiological surveys taken by the technician were not performed or'recorded in accordance with established procedures.
In Appendix A, the violation is addressed with an explanation
A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.  
of our position regarding validity, corrective
 
action and date of full compliance.
Appendix A Page 2 of 2 s Tak n R 2.3.2.3.In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis.was performed for this violation.
V ery truly yours, G.D.Bouchey, Director Licensing 8 Assur ance JDA/bI<Attachments
Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.
cc: JB Hartin-NRC RV NS Reynolds-BCPIER RB Samworth-NRC DL Williams-BPA/399 ,NRC Site Inspector-901A  
Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
APPENDIX A During an NRC inspection
to be T k n I This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings, A complete gob and task analysis was recently.completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.a e Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.
conducted on January 29,-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements
AccELERATED DIAklBU'noN DE M 04sTRAQloN sYsTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)" CESSiON NBR!9004200708 DOC.DATE: 90/04/ll NOTARIZED:
was identified.
NO DOCKET ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION BOUCHEY,G.D.
In accordance
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
with the"General Statement of Policy and Procedure for NRC Enforcement
 
Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A.10 CFR 20.201,"Surveys.," states in part: (a)'As used in the regulations
==SUBJECT:==
in this part,"survey" means an evaluation
Responds to NRC 900312 ltr re violations noted in Insp Rept 50-397/90-01.
of the radiation hazards incident to...presence
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL j SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS2 RES/DSR/HFB/HFS EXTERNAL: LPDR NSZC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME SAMWORTHPR AEOD AEOD/TPAD NRR SHANKMANPS NRR/DOEA DZR 11 NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR REG PILE 02 RGN5 PILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1/'D S h NCTE'IO ALL"RIES" RECIPZENIS'LEASE HELP US K)RE&#xc3;)CE HASTE!CXNZACI'IHE DOCUME&#xc3;7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24  
of radioactive
 
materials...Mhen
a+i WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington Way~Richland, Washington 99352 April 11, 1990 G02-90-074
appropriate, such evaluation
" Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C.20555 Gentlemen:
includes.;.measurements
 
of levels of radiation or concentrations
==Subject:==
of radioactive
NUCLEAR PLANT NO.2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
material present.(.b)Each Licensee shall make or cause to be made such surveys as...are reasonable
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
under the circumstances
Very truly yours, G.D.Bouchey, Director Licensing 8 Assurance JDA/bk Attachments cc: JB Hartin--NRC RV NS Reynolds-BCPItR RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A 5000397 PDP ADQCK 050 Q Q(o APPENOIX A Ouring an NRC inspection conducted on January 29-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.
to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals
In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A~10 CFR 20.201,"Surveys.," states in part: (a)As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...When appropriate, such evaluation includes...measurements of levels of radiation or concentrations of radioactive material present.(b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.
were permitted to handle filter elements without prior or concurrent
Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.
surveys of the levels of beta radiation.
This is a Severity Level IV violation (Supplement IV).Validit of Violation The Supply System acknowledges the validity of this violation.
Subsequent
The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential for the spread of contamination.
surveys found removable levels of radioactive
Furthermore, radiological surveys taken by the technician were not performed or recorded in accordance with established procedures.
contamination
A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.
from the filter elements ensuring up to 200 mrad per hour of beta radiation.
Appendix A Page 2 of 2 Corrective Ste s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis was performed for this violation.
This is a Severity Level IV violation (Supplement
Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.2.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.
IV), Val i f Viola n The Supply System acknowledges
3.Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
the validity of this violation.
Corrective Action to be Taken 1.This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings.2.3.A complete job and task analysis was recently completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.Oate of.Full Com liance Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.}}
The reason for the violation was personnel performance
based in that the Health Physics Technician
involved failed to take appropriate
actions to reduce the potential For the spread of contamination.
Furthermore, radiological
surveys taken by the technician
were not performed or'recorded in accordance
with established
procedures.
A contributing
factor for this violation was that the pre-job coordination
and briefings were less than adequate.  
Appendix A Page 2 of 2 s Tak n R 2.3.2.3.In addition to the initial cause analysis performed as part of the Radiological
Occurrence
Report (ROR)for this event, a formal Root Cause Analysis.was performed for this violation.
Several recommendations
for improvements
were identified
and included I)evaluating
the Health Physics Program for enhancements
in assessing radiological
considerations
during the work planning cycle, and 2)providing for increased supervisory
overview of Health Physics work coverage.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision
prior to implementation.
Increased emphasis is being applied in the area of supervisory
overview of Health Physics work in progress to improve evaluation
of personnel performance.
to be T k n I This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician
meetings, A complete gob and task analysis was recently.completed
for the Health Physics Technician
Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance
based)rather than theory based.Another improvement, that relates specifically
to this violation, is that the new program will include training on the fundamentals
and expectations
of providing job coverage.An overall evaluation
of the Health Physics Program will be performed to determine if improvements
need to be made in assessing radiological
considerations
during the work planning cycle.Included in the evaluation
will be a review of the pre-and post-job review process.a e Although the Supply System is currently in full compliance, the overall evaluation
of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.  
AccELERATED
DIAklBU'noN
DE M 04sTRAQloN
sYsTEM REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RZDS)" CESSiON NBR!9004200708
DOC.DATE: 90/04/ll NOTARIZED:
NO DOCKET ACIL:50-397
WPPSS Nuclear Project, Unit 2, Washington
Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION
BOUCHEY,G.D.
Washington
Public Power Supply System RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 900312 ltr re violations
noted in Insp Rept 50-397/90-01.
DISTRIBUTION
CODE: IE01D COPIES RECEIVED:LTR
I ENCL j SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES: RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB
DEDRO NRR/DLPQ/LPEB10
NRR/DREP/PEPB9D
NRR/DST/DIR
SE2 NUDOCS-ABSTRACT
OGC/HDS2 RES/DSR/HFB/HFS
EXTERNAL: LPDR NSZC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME SAMWORTHPR
AEOD AEOD/TPAD NRR SHANKMANPS
NRR/DOEA DZR 11 NRR/DRIS/DIR
NRR/PMAS/ILRB12
OE DIR REG PILE 02 RGN5 PILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1/'D S h NCTE'IO ALL"RIES" RECIPZENIS'LEASE
HELP US K)RE&#xc3;)CE HASTE!CXNZACI'IHE
DOCUME&#xc3;7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24  
a+i WASHINGTON
PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington
Way~Richland, Washington
99352 April 11, 1990 G02-90-074
" Docket No.50-397 U.S.Nuclear Regulatory
Commission
Attn: Document Control Desk Hail Station Pl-137 Washington, D.C.20555 Gentlemen:
Subject: NUCLEAR PLANT NO.2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION
REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington
Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990.Our reply, pursuant to the provisions
of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
In Appendix A, the violation is addressed with an explanation
of our position regarding validity, corrective
action and date of full compliance.
Very truly yours, G.D.Bouchey, Director Licensing 8 Assurance JDA/bk Attachments
cc: JB Hartin--NRC RV NS Reynolds-BCPItR RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A 5000397 PDP ADQCK 050 Q Q(o  
APPENOIX A Ouring an NRC inspection
conducted on January 29-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements
was identified.
In accordance
with the"General Statement of Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A~10 CFR 20.201,"Surveys.," states in part: (a)As used in the regulations
in this part,"survey" means an evaluation
of the radiation hazards incident to...presence
of radioactive
materials...When
appropriate, such evaluation
includes...measurements
of levels of radiation or concentrations
of radioactive
material present.(b)Each Licensee shall make or cause to be made such surveys as...are reasonable
under the circumstances
to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals
were permitted to handle filter elements without prior or concurrent
surveys of the levels of beta radiation.
Subsequent
surveys found removable levels of radioactive
contamination
from the filter elements ensuring up to 200 mrad per hour of beta radiation.
This is a Severity Level IV violation (Supplement
IV).Validit of Violation The Supply System acknowledges
the validity of this violation.
The reason for the violation was personnel performance
based in that the Health Physics Technician
involved failed to take appropriate
actions to reduce the potential for the spread of contamination.
Furthermore, radiological
surveys taken by the technician
were not performed or recorded in accordance
with established
procedures.
A contributing
factor for this violation was that the pre-job coordination
and briefings were less than adequate.  
Appendix A Page 2 of 2 Corrective
Ste s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological
Occurrence
Report (ROR)for this event, a formal Root Cause Analysis was performed for this violation.
Several recommendations
for improvements
were identified
and included I)evaluating
the Health Physics Program for enhancements
in assessing radiological
considerations
during the work planning cycle, and 2)providing for increased supervisory
overview of Health Physics work coverage.2.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision
prior to implementation.
3.Increased emphasis is being applied in the area of supervisory
overview of Health Physics work in progress to improve evaluation
of personnel performance.
Corrective
Action to be Taken 1.This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician
meetings.2.3.A complete job and task analysis was recently completed for the Health Physics Technician
Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance
based)rather than theory based.Another improvement, that relates specifically
to this violation, is that the new program will include training on the fundamentals
and expectations
of providing job coverage.An overall evaluation
of the Health Physics Program will be performed to determine if improvements
need to be made in assessing radiological
considerations
during the work planning cycle.Included in the evaluation
will be a review of the pre-and post-job review process.Oate of.Full Com liance Although the Supply System is currently in full compliance, the overall evaluation
of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.
}}

Revision as of 13:11, 17 August 2019

Responds to NRC 900312 Ltr Re Violations Noted in Insp Rept 50-397/90-01.Corrective Actions:Complete Job & Task Analysis Completed for Health Physics Technician Training Program & New Program Will Include Training on Fundamentals
ML17285B188
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/11/1990
From: Bouchey G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-90-074, GO2-90-74, NUDOCS 9004200708
Download: ML17285B188 (9)
v • d • e


Text

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 988<3000 George Wash/ngton Way~Rfrhland, Washlngton 893$2 April 11, 1990 602-90"074 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C, 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO.2, OPERATING LICEHSE NO.NPF-21 HRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.

V ery truly yours, G.D.Bouchey, Director Licensing 8 Assur ance JDA/bI<Attachments cc: JB Hartin-NRC RV NS Reynolds-BCPIER RB Samworth-NRC DL Williams-BPA/399 ,NRC Site Inspector-901A APPENDIX A During an NRC inspection conducted on January 29,-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A.10 CFR 20.201,"Surveys.," states in part: (a)'As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...Mhen appropriate, such evaluation includes.;.measurements of levels of radiation or concentrations of radioactive material present.(.b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.

Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.

This is a Severity Level IV violation (Supplement IV), Val i f Viola n The Supply System acknowledges the validity of this violation.

The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential For the spread of contamination.

Furthermore, radiological surveys taken by the technician were not performed or'recorded in accordance with established procedures.

A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.

Appendix A Page 2 of 2 s Tak n R 2.3.2.3.In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis.was performed for this violation.

Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.

Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.

to be T k n I This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings, A complete gob and task analysis was recently.completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.a e Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.

AccELERATED DIAklBU'noN DE M 04sTRAQloN sYsTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)" CESSiON NBR!9004200708 DOC.DATE: 90/04/ll NOTARIZED:

NO DOCKET ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION BOUCHEY,G.D.

Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900312 ltr re violations noted in Insp Rept 50-397/90-01.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL j SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS2 RES/DSR/HFB/HFS EXTERNAL: LPDR NSZC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME SAMWORTHPR AEOD AEOD/TPAD NRR SHANKMANPS NRR/DOEA DZR 11 NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR REG PILE 02 RGN5 PILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1/'D S h NCTE'IO ALL"RIES" RECIPZENIS'LEASE HELP US K)REÃ)CE HASTE!CXNZACI'IHE DOCUMEÃ7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

a+i WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington Way~Richland, Washington 99352 April 11, 1990 G02-90-074

" Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C.20555 Gentlemen:

Subject:

NUCLEAR PLANT NO.2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.

Very truly yours, G.D.Bouchey, Director Licensing 8 Assurance JDA/bk Attachments cc: JB Hartin--NRC RV NS Reynolds-BCPItR RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A 5000397 PDP ADQCK 050 Q Q(o APPENOIX A Ouring an NRC inspection conducted on January 29-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A~10 CFR 20.201,"Surveys.," states in part: (a)As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...When appropriate, such evaluation includes...measurements of levels of radiation or concentrations of radioactive material present.(b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.

Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.

This is a Severity Level IV violation (Supplement IV).Validit of Violation The Supply System acknowledges the validity of this violation.

The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential for the spread of contamination.

Furthermore, radiological surveys taken by the technician were not performed or recorded in accordance with established procedures.

A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.

Appendix A Page 2 of 2 Corrective Ste s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis was performed for this violation.

Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.2.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.

3.Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.

Corrective Action to be Taken 1.This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings.2.3.A complete job and task analysis was recently completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.Oate of.Full Com liance Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.

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